G.R. No. 200180 - Cabanez vs. Solano

The administrative case arose from a letter-report dated May 25, 1993, by then Acting Register of Deeds, Atty. Artemio D. Cana, concerning the alleged falsification of an Order.
The Order in question, purportedly dated September 25, 1992, was for the reconstitution of title (TCT No. T-250603) in the context of a petition filed by Alfredo de Guzman before RTC Branch 19, Malolos, Bulacan.
The Order was allegedly issued and signed by Judge Camilo D. Montesa, Jr., but subsequent inquiry revealed that no Order or Entry of Judgment was actually issued in the ordinary proceedings of that case.

The spurious Order was presented to Atty. Cana by Enrico Fombo, who had obtained it from Mr. Gerardo Flores, the attorney-in-fact for petitioner Alfredo de Guzman.
Further investigation showed that respondent Belen D. Santos, a stenographic reporter from Branch 6 of the Malolos RTC, was the person who provided the Order to Mr. Flores.
A similar pattern was observed with two additional Orders, both dated February 15, 1993, relating to petitions for reconstitution of title filed by Angel Vasallo with Aurelia Jose and Rosalina Gabriel.
In these instances, Mr. Gerardo Flores was likewise the representative for the petitioners, and the Orders were obtained through an arrangement involving respondent Santos.

Upon receiving the letter-report from Atty. Cana, Executive Judge Natividad Dizon referred the matter to Vice-Executive Judge Demetrio B. Macapagal and the Criminal Investigation Service (CIS) of the PNP for further investigation.
The CIS conducted an investigation which resulted in the filing of Information against respondent Santos for three counts of falsification of public documents, based on the irregularities surrounding the Orders.
Several administrative recommendations were made, including one from Vice-Executive Judge Macapagal, Sr., urging the filing of administrative charges against respondent Santos.

Atty. Cana submitted an affidavit on April 26, 1994, reiterating the factual background contained in his earlier letter-report, serving as his direct testimony.
Respondent Santos submitted her own affidavit on May 3, 1994, denying her involvement in the alleged issuance of the spurious orders while claiming disassociation from the dubious transactions.
Mr. Gerardo Flores, in his sworn statement dated July 14, 1993, admitted that he and Santos had an arrangement whereby she handled the filing and processing of the reconstitution petitions, supplying her with the orders which he later discovered to be spurious.

Although there was no direct evidence proving that respondent Santos authored the spurious Orders, substantial evidence showed her active participation in processing them for monetary consideration.
Her actions were found to be prejudicial to the interests of the judicial service, notably because government employees are forbidden from engaging in financial transactions that could affect their impartial performance of duties.
The investigation emphasized that her conduct compromised the integrity of the court’s administrative processes, leading to the subsequent administrative sanctions imposed against her.

Whether respondent Belen D. Santos, despite not being the actual author of the spurious Orders, bore sufficient responsibility for the falsification of public documents through her participation in processing these orders.
Whether her acceptance of monetary consideration and involvement in facilitating the reconstitution petitions violated the standards expected of government employees.

Whether the administrative investigation could proceed given that there was no direct evidence of her commissioning or issuing the documents, but only evidence of complicity through her actions.
Whether the withdrawal of criminal complaints by the complainants (Gerardo Flores and Alfredo de Guzman) should affect the continuation of the administrative investigation.

Whether the conduct of respondent Santos—being outside her designated official duties by leaving her post to process cases from another branch—constituted a violation of the strict ethical standards required of court employees.
Whether such conduct is prejudicial to the efficient delivery of justice and undermines public confidence in the judicial system.